Privacy Policy of Golden Horizon Sunset Club

Effective Date: April 27, 2026

1. Introduction and Company Information

This Privacy Policy explains how Golden Horizon Sunset Club (“we,” “us,” “our,” or the “Company”) collects, uses, stores, discloses, and protects personal information in connection with our sunset-club services, including membership inquiries, reservations, event attendance, guest registration, customer support, marketing, website use, and related services.

We are committed to complying with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission of the Philippines.

Data Controller / Operator: Golden Horizon Sunset Club
Address: Unit 12, 3rd Floor, Ayala Triangle Gardens Tower 2, Paseo de Roxas, Makati City, Metro Manila 1226, Philippines
Email: [email protected]
Phone: +63 2 8847 3925

2. Data Collection and Processing

We may collect and process the following categories of personal information, depending on your interaction with us:

• Identity and contact details: full name, nickname, email address, mobile number, mailing address, company name, and social media handle if you contact us through those channels.
• Membership and reservation details: membership type, booking dates, guest counts, table or event preferences, special requests, attendance history, and transaction references.
• Payment-related information: billing details, payment status, and limited payment records necessary to process transactions. We generally do not store full card details if payments are handled by third-party payment processors.
• Identification and verification data: government-issued ID details or age verification information where required for entry, security, compliance, or fraud prevention.
• Event and venue-related information: photographs, CCTV footage, entry logs, and incident reports collected for safety, security, and operational purposes.
• Technical data: IP address, device identifiers, browser type, pages visited, cookies, and usage analytics when you use our website or digital services.
• Communications: inquiries, feedback, complaints, survey responses, and correspondence with our staff.
• Marketing preferences: consent choices, subscription status, and communication preferences.

We may collect personal information directly from you, from your authorized representatives, from our service providers, from payment processors, from reservation platforms, or automatically through our website and digital tools.

We do not intentionally collect sensitive personal information unless necessary and permitted by law, such as for identity verification, health and safety accommodations, incident handling, or compliance with legal obligations.

3. Purpose of Data Processing

We process personal information for the following purposes:

• to manage inquiries, reservations, memberships, guest access, and event participation;
• to verify identity, age, eligibility, and authorization for entry or membership;
• to process payments, refunds, invoices, and related financial transactions;
• to provide customer service, respond to requests, and handle complaints;
• to maintain venue safety, security, and incident management, including CCTV monitoring and access control;
• to personalize services, improve guest experience, and understand customer preferences;
• to send service-related notices, updates, reminders, and administrative communications;
• to send marketing communications, promotions, and event invitations where permitted by law and subject to your preferences;
• to comply with legal, regulatory, tax, accounting, and reporting obligations;
• to detect, investigate, and prevent fraud, unauthorized access, misconduct, and other unlawful activity;
• to establish, exercise, or defend legal claims;
• to conduct analytics, business planning, and service improvement;
• to administer our website, systems, and records.

4. Legal Basis for Processing

We process personal information only when there is a lawful basis under applicable Philippine privacy laws, including:

• Consent: where you have given clear and informed consent, such as for certain marketing communications, optional cookies, or specific disclosures.
• Contractual necessity: where processing is necessary to perform our obligations in relation to memberships, reservations, event bookings, and related services.
• Compliance with legal obligations: where processing is required to comply with laws, regulations, lawful orders, or regulatory requirements.
• Legitimate interests: where processing is reasonably necessary for our legitimate business interests, such as security, fraud prevention, service improvement, and internal administration, provided that your rights and freedoms are not overridden.
• Vital interests: where necessary to protect life, health, or safety in emergency situations.
• Public interest or lawful authority: where applicable under Philippine law.

5. Data Sharing and Third Parties

We may share personal information with third parties only as necessary and subject to appropriate safeguards. These may include:

• Service providers: IT hosting providers, cloud storage providers, reservation systems, customer support tools, analytics providers, email/SMS platforms, and security vendors.
• Payment processors and financial institutions: to process payments, refunds, chargebacks, and fraud checks.
• Professional advisers: lawyers, auditors, accountants, consultants, and insurers.
• Government authorities and regulators: when required by law, court order, subpoena, or lawful request.
• Event partners and venue collaborators: where necessary to manage co-hosted events, guest lists, or related services.
• Security personnel and emergency responders: for venue safety, incident response, and protection of persons and property.

We require third parties to process personal information only for authorized purposes and to implement reasonable confidentiality and security measures. Where a third party acts as a personal information processor, we seek appropriate contractual protections consistent with applicable law.

6. Data Transfer to Third Countries

Some of our service providers may be located outside the Philippines or may store or access data in other countries. As a result, your personal information may be transferred to, stored in, or processed in jurisdictions outside the Philippines, including countries that may have different data protection standards.

When we transfer personal information internationally, we take reasonable steps to ensure that appropriate safeguards are in place, such as contractual protections, security measures, and due diligence on recipients, in accordance with applicable Philippine privacy requirements.

7. Storage Duration

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Membership, reservation, and transaction records: retained for the duration of the relationship and for a reasonable period thereafter for accounting, audit, tax, dispute resolution, and legal compliance.
• Customer service and communication records: retained as needed to address inquiries, complaints, and service history.
• Security records, including CCTV footage and access logs: retained for a limited period unless needed for investigation, incident response, or legal proceedings.
• Marketing consent and preference records: retained until you withdraw consent or opt out, subject to legal retention requirements.
• Legal and compliance records: retained for the period required by applicable law or regulatory guidance.

When personal information is no longer needed, we will securely delete, anonymize, or dispose of it in accordance with our retention and disposal procedures.

8. User Rights

Subject to applicable law and verification of identity, you may exercise the following rights with respect to your personal information:

• Right to access: request information about whether we process your personal data and obtain a copy of it.
• Right to rectification: request correction of inaccurate, incomplete, outdated, or misleading information.
• Right to erasure or blocking: request deletion or blocking of personal data, subject to legal and contractual limitations.
• Right to restriction: request that we limit the processing of your personal data in certain circumstances.
• Right to data portability: request a copy of personal data you provided to us in a structured, commonly used, and machine-readable format, where applicable.
• Right to object: object to processing based on legitimate interests or direct marketing, subject to lawful exceptions.

To exercise these rights, please contact us using the details provided below. We may need to verify your identity and may decline requests where permitted by law, such as when compliance would violate legal obligations, compromise security, or adversely affect the rights of others.

9. Withdrawal of Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.

If you withdraw consent for certain processing activities, we may no longer be able to provide some services or communications, such as promotional updates or optional features, but we will inform you if this is the case.

You may opt out of marketing communications by following the unsubscribe instructions in our messages or by contacting us directly.

10. Right to Complain

If you believe that your privacy rights have been violated or that we have not adequately addressed your concerns, you may file a complaint with us first so we can investigate and respond.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines or any other competent authority, subject to applicable procedures and jurisdictional requirements.

11. Data Security

We implement reasonable and appropriate organizational, physical, and technical security measures to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. These measures may include:

• access controls and role-based permissions;
• confidentiality obligations for personnel and contractors;
• secure storage and encryption where appropriate;
• network and endpoint security measures;
• monitoring, logging, and incident detection;
• regular review of security practices and vendor safeguards;
• physical security measures for premises and records;
• incident response and breach management procedures.

While we take reasonable steps to protect your information, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

12. Contact Information

If you have questions, requests, or concerns regarding this Privacy Policy or our data processing practices, please contact:

Golden Horizon Sunset Club
Unit 12, 3rd Floor, Ayala Triangle Gardens Tower 2, Paseo de Roxas, Makati City, Metro Manila 1226, Philippines
Email: [email protected]
Phone: +63 2 8847 3925

13. Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any revised version will be posted on our website or otherwise made available to you, and the “Effective Date” will be updated accordingly.

We encourage you to review this Privacy Policy periodically. Your continued use of our services after any update constitutes acknowledgment of the revised policy to the extent permitted by law.